SETTLEMENT AGREEMENTSettlement Agreement • September 15th, 2010 • California
Contract Type FiledSeptember 15th, 2010 JurisdictionThis Settlement Agreement (“Agreement,” the terms of which are sometimes referred to as the “Settlement”) is entered into by and between Ilene Moreno (“Moreno”), Cheryl James-Ward (“James-Ward”), LaRay Peterson (“Peterson”), Henry De leon (“De leon”), Anthony Gonzalez (“Gonzalez”), and Kyle Lanesey (“Lanesey”) (collectively, “Plaintiffs”), on the one hand, on behalf of themselves and all other individuals who are members of the Class as defined in Section III below, and defendant Buena Vista Catalogue Co., d/b/a Disney Movie Club (“Disney” or “Defendant”), on the other hand. Each of the foregoing is a “Party” (collectively, the “Parties”).